Massy Gases and Energy Businesses Anti-Bribery and Compliance - Learning Tool 13 …

By nealandmassygroup | Updated: June 20, 2024, 1:56 a.m.

Slideshow Video

SHARE THE AWESOMENESS

Massy Gases and Energy Businesses ABC Policy video

Training

create your own animated videos for free

_abc cc

* Powtoon is not liable for any 3rd party content used. It is the responsibility of each user to comply with 3rd party copyright laws.

Embed code

Select a size, the embed code changes based on your selection.

_abc Powtoon Transcript

Massy Gases and Energy Businesses Anti-Bribery and Compliance Policy
 Policy Approved April 21st, 2021
Why an ABC Policy?
Establish our reputation for high ethical standards.
Attract like-minded business partners as we pursue M&A transactions.
Make financial transactions faster and more efficiently.
Creates a process to assess suppliers, contractors and agents quickly and in line with our values.
Definitions
Bribery: means giving or receiving an unearned reward to influence someone's behaviour. “Kick back”
Corruption: is any unlawful or improper behaviour that seeks to gain an advantage through illegitimate means.
Facilitation Payments: are sums of money paid to an official to speed up or "facilitate" their actions. That's why they are sometimes referred to as "grease" or "speed" payments.
What's Our Objective?
This Anti-Bribery and Corruption Compliance Policy demonstrates how the Group’s values are applied in our business transactions and behaviours. Form standards that demonstrate our commitment to doing business.
Scope
This Policy applies to all employees, directors, and joint venture partners of the Massy Gases and Energy Businesses and their third-party agents. 
Benefits of the ABC Policy
A robust policy that can withstand regulatory scrutiny.
Mitigate the risk of compliance violations by providing employees and third parties with the knowledge they need to comply with key regulations.
Improve learner engagement and onboarding experience.
Opportunity to improve Vendor Management to improve efficiency.
Sets a strong platform for future strategic initiatives with new partners
The following policies are within the remit of the Compliance function and must be distinguished from HR policies.

Customised training on these policies will be provided through our partnership with TRACE.
Suite of Governance  Policies
Be familiar with the policies
Be role Models
Set the highest standards of ethical behaviour
Make people comfortable to air concerns
Be consistent in enforcing policies
Set expectations around compliance
Leadership
Behave in a manner that is safe, ethical and consistent with Massy’s core values
Employee 
You are responsible for yourself and your fellow employees.
Shared Responsibility
Roles and Responsibilities of the Business Ethics Committee
Board Appointed Committee that meets frequently to :
1. Review effectiveness of Training programme for Employees and Suppliers and recommend changes.
2. Provide advice on Ethical Issues raised by HR or by the Tenders Committee.
3. Review complaints from Suppliers on Ethical, Bribery and Corruption Issues.
4. Establish guidelines on gifts and entertainment. Assess items that represent a possible conflict or appearance of conflict.

5. Review and approve risk assessment criteria for Contracts, Bids/Tenders and Suppliers. (at least annually)

Government Official
“Government or Public Official” is VERY WIDELY DEFINED and includes:
Foreign Officials
Employees of state-owned enterprises, including State Oil Company (SOC) employees
Political parties & candidates for political office
Members of royal families who may lack “official” authority but maintain ownership/managerial interest in Government enterprises
Officials of public international organizations (UN, World Bank)
Bribery
All forms of bribery and corruption are prohibited!
Requests to accelerate transactions, provide assurances or enhance a relationship will not be tolerated.  
Each subsidiary should implement a compliance programme that identifies the departments, positions, transactions, and relationships where there is a higher risk for bribery, and which applies an enhanced due diligence programme to these areas. 
Each subsidiary is responsible for the development of procedures and a compliance training and monitoring programme.
Corruption
1. Each Subsidiary should review its transactions and relationships with public and government officials.
2. Identify areas where staff, joint venture partners, and third-party agents are most vulnerable to involvement  in practices that may appear to be corrupt.
3. Risk informed due diligence procedures should be put in place.
4. Sharing of any material that is private information that can influence the outcome of a transaction in a manner that prejudices one party or gives an undue and unfair advantage to an individual in the company or to an external third party is prohibited.
If a subsidiary chooses to allow the giving or receipt of gifts, the subsidiary shall ensure that the following minimum requirements are met:
We will only give or accepts gifts and entertainment that are:
- Related to a business purpose
- Not material in value or frequent
- In compliance with domestic laws and the Group Code of Ethics
Giving and Receipt of Gifts and Donations Checklist
Conflict of Interest
All subsidiaries must avoid behaviours and transactions that represent or can be perceived to represent a conflict of interest whenever possible.

Each company should develop a reporting and disclosure process that is monitored by the Anti-Bribery and Corruption Compliance Officer or the Business Ethics Committee to deal with these instances in an ethical, responsible and transparent way.

Conflict of Interest activities extend to:

- Employees and relatives of staff

- The sharing of material and non-public information,

- The recruitment and hiring of staff,

- The award of contracts and tenders,

- The procurement of goods and services, and

- The use of contractors and consultants.

Fraudulent activities are not tolerated.
All payments should be made in accordance with strong controls that include appropriate separation of duties and adequate supporting documentation. 
Fraud
Each subsidiary must ensure that there is a due diligence programme in place for all third parties that is appropriate to the risk profile of each third-party relationship. 
Third-Party and Supplier Risk Assessment and Due Diligence
Create a base for making decisions regarding the continuation/non-continuation of business relationships.Revise risk assessment.Define Risk mitigation measures as needed.
Ensure to include training and periodic risk-based audits of 3rd party relationships.
Each subsidiary should complete a risk assessment of transactions.The risk assessment will guide the level of due diligence which should be put in place for each area. 
Establish an appropriate due diligence process.Additional background checks should be put in place for high risk based transactions.Document each stage of the process.
Risk Assessment

Ongoing Due Diligence

Due Diligence

Post Approval Due Diligence

For effective implementation of this Policy, there should be proper communication of the Code of Conduct and Anti-Corruption compliance  programmes to:
*  Relevant stakeholders
*  Personnel
*  Business associates
*  Governmental authorities
*  Civil society
Training and Communication
If you suspect or are aware of breaches to the Anti-Bribery and Corruption Policy here are some ways  you can report them to:
Speak Up (whistleblowing) hotline account 
Group Internal Auditor
Any member of the Portfolio Audit and Risk Committee
Portfolio Chairman
Human Resources 
Monitoring and Reporting
Retaliation for reporting of misconduct by others that are made in good faith will not be tolerated 
All investigations into breaches of the Policies shall be completed with the highest level of fairness and integrity.
There is zero tolerance for unethical and/or illegal behavior.
Non-Compliance with the Policy

Massy Gases and Energy Businesses Anti-Bribery and Compliance - Learning Tool 13 …

Copy this link to share with friends and colleagues:

WELCOME TO POWTOON!